20101124PAC to PIIC 153, 155-159, etc.pdf

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November 23,2010
Melinda Davison
Davison Van Cleve, P.C.
333 S.W. Taylor St., Ste. 400
Portland, Oregon 97204
RE: ID PAC-E-1O-07
PIlC Data Request (150-176)
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Please find enclosed Rocky Mountain Power's responses to PIlC Data Requests 153,155-
159,161-162,165,169-174,176. The remainng responses will be provided separtely.
If you have any questions, please feel free to call me at [phone].
Sincerely,
J. .I.- l¿t-~~ I~
J. Ted Weston
Manager, Regulation
Enclosure:
cc: Jean JewelllIPUC (C)/ 3 copies
Enc Olsen/lIP A (C)
Ben Otto/ICL (C)
Randill Budge/Monsanto (C)
James R. Smith/onsanto (C)
Richard AndersonIonsanto (C)
George C. Carer, III/Monsanto (C)
Dennis Peseau/onsanto (C)
Gareth R. Kajander/Monsanto (C)
Maunce Brubaker/Monsanto (C)
Bnan Collns/Monsanto (C)
Michael Gormanonsanto (C)
Kathn Iverson/Monsanto (C)
Mark Widmer/Monsanto (C)
Greg Meyer/PIlC (C)
Don Shoenbeck/PIlC (C)
PAC-E-I0-07/Rocky Mountain Power
November 23,2010
PILC Data Request 153
PIle Data Request 153
Please refer to Shu-Di-Reb-3, lines 6-8. Do the figures quoted reflect regulatory
adjustments, such as imputation of SMUD contract revenues, and removal of out
of period costs? If so, please restate the figues with those adjustments.
Response to PIle Data Request 153
No, as stated in the testimony of Dr. Shu, the quoted numbers are actuil net power
costs. The reference adjustment for the SMUD contract is less than $10 millon
on a total Company basis for a 12-month penod.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-10-07/Rocky Mountan Power
November 23,2010
PILC Data Request 155
PIle Data Request 155
Please refer to Shu-Di-Reb-3, lines 6-8. Has Dr. Shu made any anilysis of the
extent to which load vanations, hydro and wind generation deviations, or the like
have impacted the level ofNPC for the penods referenced.
Response to PIle Data Request 155
No.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-1 0-07/Rocky Mountain Power
November 23,2010
PIlC Data Request 156
PIle Data Request 156
Please refer to Shu-Di-Reb-3, lines 6-8. Has Dr. Shu performed any analysis of
and demonstrated the prudence ofthe costs referenced? Ifnot, what is Dr. Shu's
basis for assuming the costs listed were in fact, all prudent?
Response to PIle Data Request 156
No. The Company continumly strives to operate in a prudent maner. The
Company believes that all of the listed costs are incured prudently to serve its
obligations.
Recordho1der:
Sponsor:
Hui Shu
Hui Shu
PAC-E-I0-07/Rocky Mountain Power
November 23,2010
PILC Data Request 157
PIle Data Request 157
Please refer to Shu-Di-Reb-3, lines 6-8. Does Dr. Shu agree that in all of the
Wyomig PCAM cases the Company has agreed to reductions to its requested
actual net power costs, as par of a stipulation?
Resiionse to PIle Data Request 157
Yes.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-10-07/Rocky Mountain Power
November 23,2010
PILC Data Request 158
PIle Data Request 158
Please refer to Shu-Di-Reb-3, line 10. a.) Is it Dr. Shu's position that so long as
actual NPC is less than normilized NPC that no adjustment or even correction to
GRID model results is reasonable? b.) For example, would correction of a math
error in GRID be uneasonable in Dr. Shu's view under curent circumstaces?
Response to PIle Data Request 158
a. No.
b. No.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-1 0-07/Rocky Mountain Power
November 23,2010
PIlC Data Request 159
PIle Data Request 159
Please refer to Shu-Di-Reb-3, lines 20-23. Is it Dr. Shu's position that only a
complete "cost plus" type ofECAM arangement provides the Company a fair
opportty to recover its power costs?
Response to PIle Data Request 159
No.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-l 0-07/Rocky Mountain Power
November 23,2010
PIlC Data Request 161
PIle Data Request 161
Please refer to Shu-Di-Reb-3, lines 20-23 top page 4, line 1. Does Dr. Shu
acknowledge that at the time the Company made its Idaho filing it was aware that
its projected NPC dunng the rate effective penod was much higher th the
amount it was requesting in the test year?
Response to PIle Data Request 161
Yes.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-IO-07/Rocky Mountain Power
November 23,2010
PIlC Data Request 162
PIle Data Request 162
Please refer to Shu-Di-Reb-5, lines 4-10. Did Dr. Shu apply the modified
screenig analysis to all gas fired plants? Identify the resources to which the
screens were applied. To the extent not provided previously, please provide the
workpapers for the new screens.
Response to PIle Data Request 162
The modified screenig anilysis was applied to the Gadsby Steam unts, the
Gadsby CTs, Curant Creek, Lake Side, and Chehmis. The Hermiston unts were
not screened since the gas supply contract rates in effect in the test penod were
significantly cheaper than market rates. Please refer to the Company's response
to PILC Data Request 144.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-I0-07/Rocky Mountain Power
November 23,2010
PIlC Data Request 165
PIle Data Request 165
Please refer to Shu-Di-Reb-14, lines 9-11. Does Dr. Shu consider BPA's practice
of charging wholesale transmission customers for wind integration services
reasonable? Please explain why PacifiCorp's transmission ta:fs contain no
charge for wid integration services.
Response to PIle Data Request 165
a. Yes
b. Wind integration has only recently begu to playa signficant role on the
Company's transmission system. BPA's rates do not have to meet FERC's
just and reasonable standard, so it has been able to more quickly adapt its
ta:frates to reflect changes on its systems. Please refer to Dr. Shu's rebutt
testimony from page 5, line 12 to page 17, line 2.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-l 0-07/Rocky Mountain Power
November 23,2010
PILC Data Request 169
PIle Data Request 169
Please refer to Shu-Di-Reb-23 Figue 1. Does Dr. Shu acknowledge that Bear
River energy production in 1994 was approxiately the same as the most level
shown on the char and that by 1996 Bear River was operating in Flood Control
mode.
Response to PIle Data Request 169
No.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-1 0-07/Rocky Mountain Power
November 23, 2010
PILC Data Request 170
PIle Data Request 170
Please refer to Shu-Di-Reb-23 Figue 1. Does Dr. Shu believe that in 1986 it
would have been proper to assume that the Company would never be in drought
conditions in prepanng its NPC forecasts?
Respone to PIle Data Request 170
No.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-1 0-07/Rocky Mountain Power
November 23,2010
PILC Data Request 171
PIle Data Request 171
Please refer to Shu-Di-Reb-23 Figue 1. Does Dr. Shu see any evidence in this
figue to demonstrate that recent pnor history is usefu in predicting the presence
or absence of flood control operations of the Bear River facilty? If so, please
indicate how she would use ths data to make such predictions.
Response to PIle Data Request 171
Yes. The Company does look to the histoncil information to set expectations for
the test period. The recent history indicated that the Company has not been
operating in the flood control mode since 2001. And, given the curent elevation
of the Bear Lake, the Company is not expected to operate in the flood control
mode in the near futue. Please refer to Dr. Shu's rebuttal testimony for fuher
discussion, especially from page 20, line 16 to page 21, line 9.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
P AC-E-l 0-07/Rocky Mountain Power
November 23,2010
PILC Data Request 172
PIle Data Request 172
Please refer to Shu-Di-Reb-24 line 17. Provide workpapers supporting the figue
$4.7 millon.
Response to PIle Data Request 172
Please refer to the Company's response to PILC Data Request 143.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-I0-07/Rocky Mountan Power
November 23,2010
PILC Data Request 173
PIle Data Request 173
Please refer to Shu-Di-Reb-24 line 17. Explain how the $4.7 milion figue is
relevant given the fact that the Company has changed is screenig methodology in
ths case.
Response to PIle Data Request 173
Mr. Falkenberg's stap cost adjustment (#2) is based on the screens originally
filed by the Company.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-1 0-07/Rocky Mountain Power
November 23,2010
PILC Data Request 174
PIle Data Request 174
Please refer to Shu-Di-Reb-24 line 17. Provide the same anlysis as applies to the
$4.7 millon but for the Company's rebutt NPC filing.
Response to PIle Data Request 174
The Company has not conducted the requested analysis.
Recordholder:
Sponsor:
Hui Shu
Hui Shu
PAC-E-10-07/Rocky Mountain Power
November 23,2010
PUC Data Request 176
PIle Data Request 176
Please refer to Shu-Di-Reb-38 line 1-11. Does Dr. Shu agree that one of the
ultimate benefits of the new transmission line would be to eliminate the need
for short-term transmission purchases, such as the contract in question?
Response to PIle Data Request 176
No. Please refer to Mr. Cupparo's testimony for discussion on the puroses and
benefits of the new transmission line.
Recordholder:
Sponsor:
Hui Shu / John Cupparo
Hui Shu / John Cupparo